SCHEDULES
SCHEDULE 32 PETROLEUM REVENUE TAX: UNRELIEVABLE FIELD LOSSES
7Loss to be relieved against other participators’ profits
1
The intermediate unrelieved loss shall (but only for the purposes of determinations under this Schedule) be relieved against relevant profits accruing to a different owner.
2
The provisions of paragraphs 8 to 10 apply for the purposes of relieving the intermediate unrelieved loss under this paragraph.
3
In this paragraph and paragraph 8, a “different owner” means any participator in the field who—
a
has the loss-maker’s interest at any time (whether before or after the transfer) when the loss-maker does not have that interest, or
b
has a part of the loss-maker’s interest at any time (whether before or after the transfer) when the loss-maker does not have that part.
4
In sub-paragraph (3) “the loss-maker’s interest” means—
a
if the loss-maker is the old participator or the new participator, the transferred interest;
b
if the loss-maker is a subsequent new owner and at any time (whether before or after the transfer) has the whole of the transferred interest, that interest; and
c
if the loss-maker is a subsequent new owner and paragraph (b) does not apply, the aggregate of each part of the transferred interest that at any time (whether before or after the transfer) is a part that the loss-maker has.